Cooper v. Commissioner of Internal Revenue

DOBIE, Circuit Judge.

This is a petition for review, filed by the taxpayer, Wade H. Cooper, of federal income taxes assessed against him for the year 1946. Taxpayer appeals from a decision of the Tax Court of the United States holding that in 1946 he realized taxable income of $7,433.88, representing the difference between the amount he received from interest claims assigned to him by former bank depositors and the amount he paid for the claims.

The United States Savings Bank, of which taxpayer has been president and majority stock owner, was closed by Presidential proclamation March 6, 1933.…